SICCAR POINT

What is Siccar Point?

Siccar Point and its locality is one of the most famous and important sites in the history of science. The site is of global significance to scientists and geologists, and is the location of James Hutton's Unconformity.

This historically important location helped Hutton develop his early theories of geological time that showed that the earth was unimaginably older than anyone had known.

The site is visited by thousands of geologists and scientists every year. Every geologist you speak to will want to visit Siccar Point at least one time in their lives. That's how significant this location is.

Now a company is planning to ruin the location by digging a trench just a few meters east of this iconic location, lay a pipeline, and then fill that trench with concrete. This will cause permanent damage to the rock-bed and leave a visible scar at this important location forever.

Once the pipeline is layed they plan to pump their untreated agricultural waste - up to 360,000 litres per day - that could include vegetable matter, silt, nutrients, and other organics, straight into the sea. The whole landscape could be put in danger from accelerated erosion and the effluent that will be dumped. This could threaten not just Siccar Point and the immediate environment around it, but all the coves and inlets including Pease Bay, Cove, Coldingham Sands and Eyemouth, and the marine reserve at St Abbs, may also be at risk.

Who is planning this work - Drysdales Limited

Drysdales is a company that prepare and package a number of different varieties of vegetables for delivery to supermarkets. They process the newly harvested vegetables, clean them by washing all the earth from them, trim them, and then pre-package them for supermarket shelves.

Their plan is to dig a trench across a scientifically sensitive and important area, fill it with concrete, and dump their waste straight into the sea when they already have an excellent waste-water treatment process, and there is no economic or environmental reasons to change what systems they have.

What Happens to their Waste Water at the moment?

Drysdales currently have an excellent and environmentally friendly waste-water processing facility consisting of silt-settlement tanks, augers to remove larger vegetable waste trimmings, active sludge processes to reduce nutrients, and reed beds to give their water a final clean. This high-quality water then flows into a local burn where it is further diluted, absorbed by plants and soil, filtered by soils and strata, and ultimately flows into the sea at Meikle Poo Craig. We think this is an excellent system and should be retained.

If we haven't got the details correct we apologise to Drysdales, but we like their existing system which is why we want them to keep it.

What's the plan

The plan is to build a pumping station, lay a pipeline, and dump all this effluent directly into the Firth of Forth. There are hints that their are plans afoot to remove some of their current waste water treatment facilities and that the pipeline will be used to deposit less clean effluent than is currently being produced. In fact, their own plans appear to show that the proposed pipeline inlet is in their existing settlement lagoon, completely by-passing their reed-beds - and that is not good news considering what a couple of objectors have said about the effluent BEFORE the reed beds were introduced.

Although we're confident the location of the trench and pipe are relatively accurate the line is not to scale in any of these images.

A slightly different perspective:

Photo: Meg Stewart. Copied from site.

Another:

How much effluent are we talking about?

According to the Supporting Documents, Drysdales have plans to output around 360,000 litres of waste water into this marine evironment every single day.

According to Drysdales own web site they process over 14,000 tonnes (source: Drysdales web site) every year. Vegetable processing generates 10%-60% of the raw material as solid waste (Source: Report).

That means Drysdales could produce up to 1400 tonnes* per year at 10% wastage (3.8 tonnes per day on average) and up to 8400* tonnes at 60% wastage (23 tonnes per day on average) of raw vegetable matter. That's not taking into account seasonal variations in output.

Their current waste-water processing facilities reduce these figures by a significant amount but it is probably accurate to say that the before the waste is processed this is the quantity of waste matter being dealt with.

Facilities exist in their current water processing that reduce the amount of silt or vegetable trimmings reaching their active sludge and reed bed processes, but no filtering system is ever 100% effective. Things like the holes in the auger used to remove vegetable trimmings will allow solid vegetable matter to pass into these other processes, and the action of the auger may facilitate the production of smaller vegetable matter that will flow through the holes too. As Drysdales own pictures show in their submission, the silt removal process is not 100% effective either. At the moment, if any of this matter passes onto the active sludge system or reed beds it is going to be removed either by the action of the active-sludge process or by the reed beds.

The World Bank (Source: Report) recommends that waste water from raw vegtable production should be treated to remove all solid organic material, and that is what Drysdales currently do, but as we suggest later in this page, this may not always be so.

This Report states "The vegetable processing industry generates significant quantities of wastes in some regions. These wastes usually contain high levels of organic matter, nutrients, moisture, and sometimes salts, and are not suitable for disposal in municipal landfills because of their physical, chemical and biological properties. " so, while SEPA does not class Drysdales waste as "Hazardous", the raw waste is not exactly pleasant or completely harmless either.

We've hinted that Drydsales might planning to remove some of these processes so they can extend their factory - the active sludge and reed beds do use a lot of land. We've also heard rumours that some people think we are being inaccurate or inflamatory about the potential danger to Siccar Point from this effluent. We'll discuss that below and you can then make up your own mind, however their own plans appear to show that the proposed pipeline inlet is in their existing settlement lagoon completely by-passing their reed-beds, so maybe some changes will be immediate.

Where will this effluent end up?

Before we go any further, we must answer this essential question. The details are below and on our SNH2 Pages, but to put it simply, whatever comes out of that proposed pipeline, whether it be fresh water, water with some sugars, silt, or actual organic matter, some of it will end up on Siccar Point. How much is a matter for modelling and testing, but the location is not.

Isn't the waste water clean. That's what we've been told?

Drysdales do have an excellent, effective, and environmentally friendly, waste water treatment process at the moment - and we want them to keep every part of it. Their system uses various processes - including reed beds - and the end result of this processing is high-quality water that is then discharged into a local burn. The local burn dilutes this outflow even more, some of it will be absorbed by plants and soil, and some will be filtered by other strata. This all flows out to sea via a natural fresh-water outlet at a place called Meikle Poo Craig, approximately 1KM east of their new proposed outflow. We have no issues with this process at all.

Won't the waste water always be clean?

Anyone approaching stakeholders such as SEPA (Scottish Environment Protection Agency) will be told that the company has a CAR licence to discharge their outflow to this burn (a licence that they pay SEPA for), that the water eventually flowing out to sea is of a high quality, and that SEPA have no problem with this. They could even conceivably say that when the pipeline is [first] built the water being piped will be absolutely fine and there is nothing to be concerned about - except perhaps the influx of fresh water at that location. That's wonderful, and that seems to be the message that is given to anyone contacting them in an official capacity. It suggests (without actually saying it) that it will all remain the same over the long term....and this is where it starts to become much less attractive or clear. Their own plans appear to show that the proposed pipeline inlet is in their existing settlement lagoon, by-passing their reed-beds altogether.

Will the waste water processing change?

Drysdales submitted an "Applicants Supporting Comments" document to the council where it quoted this web site and claimed it had "significant inaccuracies" - you can see our response, and links to the document here. Even though it was a document in their defence of our "inaccuracies" it did not deny our suggestions that part of the waste-water processing could be removed (the most critical parts for clean water), but it also made a point of showing their current processing methods (of which we approve) as they are "at the moment" - our emphasis, but their words.

Why is a pipeline needed at all then?

We hadn't considered that, but Drysdales' response to this web site started us thinking about that question. Their existing system is excellent so why do they need to change it? The pipeline brings no benefits - economic, environmental, or social - and does represent a significant investment for them. It ruins a landscape when it isn't necessary and brings no benefits to the table - unless there are plans to change their waste-water processing that they aren't revealing.

Is the medium to long term plan to bury the pipeline out to sea, get planning permission based on current treatments, then change the water treatment processes when no-one can see easily see or monitor the effluent until it is too late? We don't know, but we do know they want to bulid more factory units and the only room they have on their site are the large active-sludge ponds and reedbeds that do take up a lot of ground area. A similar suggestion regarding building on the reed beds is made in the objection by TA Dykes, who farms the land at Siccar Point and up to the outflow of the reed beds, and we agree. The current waste water flows through the burn that is on his farm.

But wouldn't they require permission to make changes?

Yes they would, but it wouldn't require a planning application if the current one is passed. It would then be a matter for SEPA alone to decide what protections were needed. Other stakeholders (the Council, Community Council, and SNH) would all be consulted for their opinion but this would not be subject to the same level of scrutiny or public input that a planning application allows. There's a good chance all the current objectors from around the world would not have their voices heard. Such a plan to remove widespread public scrutiny, if that is what is happening, would be underhand, duplicitous, undemocratic, and should not be allowed.

"The effluent from this site was once poured into a stream passing through it, and it converted the stream into a very foul smelling sewer. However, the problem was dealt with very successfully by installing a reed bed.."

So will they be dumping untreated effluent?

Maybe not right away, but if their active sludge or reed bed systems are removed then absolutely yes - and their own plans appear to show that the reed-beds will be by-passed immediately. They haven't denied they have plans to remove them and we know they are looking for land to build upon. Considering there are no economic or environmental benefits to building a pipeline given their current processes, why would the company even want to build it? Is this planning application just the first-step in a process to change their existing treatment process to ones that are less effective and produce much less attractive effluent? You can make up your own mind.

In the objection by TA Dykes, who has farmed the land around Siccar Point for many years, and who has extensive experience of the quality of the water coming from the plant into the Redheugh Burn, he makes indirect reference to the quality of the water before the active sludge and reed bed system were installed. Anyone who knows or has met Tom Dykes will tell you he is a diplomatic gentleman who gets on with all his neighbours, is well known and respected locally, and also has a business relationship with Drysdales and the Trust who own the land. If he says in his objection, "I was relieved when the reed beds were installed" then you can be sure there were concerns before. Now that the reed beds and other processes are being used he states, "I confirm that the quality of this water is good". Any backward change would be a negative step for the environment.

In another objection from Mr R Turner who lives at Redheugh and knows the burn where the effluent now flows said "The effluent from this site was once poured into a stream passing through it, and it converted the stream into a very foul smelling sewer. However, the problem was dealt with very successfully by installing a reed bed, and the water in the stream has now been clear for many years."

The important thing to remember is that THAT effluent was licenced by SEPA. Do you really want that type of effluent flowing near Siccar Point? That's what might end up happening if Drysdales remove any of their waste-processing facilities - especially the reed beds.

But what's that got to do with Siccar Point?

The pipeline outflow is only 150m from Siccar Point. Not only will laying the pipeline scar and damage the immediate vicinity, but if these changes occur as we've suggested they might, it is not going to be a pleasent environment.

Will Siccar Point be damaged?

Not by the trenching or pipeline laying process - those are 150m east of Siccar Point. It will leave an unsightly scar though, and spoil the pristine landscape around Siccar Point. It will end up with an ugly concrete-filled trench running against the natural sedimentary strata in the sandstone platform that is all part of the landscape that helped Hutton develop his theories, and will be highly visible to all future visitors to Siccar Point. If the effluent does change (and we have good reasons to think that it might) then the potential damage or danger to Siccar Point itself is more obvious although it would require extensive modelling of the effluent flow to get a completely accurate picture.

The current active-sludge and reed beds remove vast amounts of organic material and nutrients, and result in the current outflow being good quality water. If these are removed then vegetable chippings, organic matter, potential pesticide and herbicides (see our response to Drysdales for more information about these) and dirty silty water will be flowing at the rate of around 360,000 litres per day. It is our belief that if this happens anyone visiting Siccar Point in the future will see a stream of discoloured water flowing from this outflow, but that might be the least of their worries. This effluent could contain organic matter, nutrients, salts, and other compounds that could be washed ashore or onto Siccar Point potentially creating a health hazard, a smell, and dirty & uhealthy intertidal zones. If the other 2 stages (silt settlement and vegetable trimmings) are removed, this will result in even less salubrious effluent and will be real eyesore.

Don't SEPA or SNH know about these potential changes or what might happen?

Not that we know of. You would think that given their experience they would be aware, but we have no evidence to suggest they do. It would be a shocking proposition and revelation if they did or had given it their unofficial or tacit approval.

Isn't this a bit speculative and scare-mongering?

Perhaps. We can't come out and say they they WILL be doing this, but with everything said above it all points to this being part of a process towards making changes to their current water treatment process - and these changes are unlikely to be for the better when it is run down a pipeline that is hidden from view.

If changes aren't being planned to their waste water treatment, then what difference will piping it away make from their current process of outflow into a local burn? It seems an awful large investment for no return or benefit.

If treatment changes ARE planned, then we can still see no reason to build the pipeline. Any environmental protections suggested by SEPA would be "on site" so surely the company could save itself a fortune by not building the pipeline and continue to use the burn - even if they have to build a small (much less expensive) pipeline the few yards to the burn? That must be the least intrusive, least expensive, and most sensible solution.

It all suggests that Drysdales know the effluent in the future is going to be so unpalatable that the easiest solution for the company is to attempt hide it from view and dump it at sea away from prying eyes, easy monitoring, and public scrutiny. We have enough issues with the location of the pipeline, but if our thinking is correct then it introduces a much more sinister and worrying element - will the effluent really be so bad that hiding it from view is the only or the best solution they can think of?

What's the Objection?

We have attempted to align our objections with the Scottish Borders Council Structural Plan, and we've dealt with the issue of 2 fronts - the pipeline route, and the effluent.

The Pipeline Route

1. The pipeline route is in an "Area of Great Landscape Value", in the area CO45 (and bordering on CO47), as designated in the "Scottish Borders Council Supplementary Planning Guidance, Local Landscape Designations, August 2012" report.
   
   The Scottish Borders Structural Plan entitled "The New Way Forward Scottish Borders Structure Plan 2001 - 2018" says:
   
   Policy N3 - National Sites
   Development proposals which will have an adverse effect, either directly or indirectly, on a Site of Special Scientific Interest will not be permitted unless:
   1. the development will not adversely affect the integrity of the site, and
   2. the development offers substantial benefits, including those of a social or economic nature, that clearly outweigh the national nature conservation value of the site.
   
   Policy N11 - Areas of Great Landscape Value
   In assessing proposals for development in Areas of Great Landscape Value, the Council will seek to safeguard landscape quality and will have particular regard to the landscape impact of the proposed development. Proposals which have a significant adverse impact will only be permitted where the impact is clearly outweighed by social or economic benefits of national or local importance
   
   Policy N12 - Coastline
   Development proposals at a coastal location will only be permitted where:
   1. the proposal is located within a defined settlement boundary or related to an existing building group; or
   2. the development requires a coastal location; and
   3. the benefits of the proposal clearly outweigh any damage to the landscape character or to the nature conservation value of the site as assessed under other relevant Plan policies
   
   The planning application may have an indirect impact on the SSSI of Siccar point and Drysdales have not shown any economic or social benefits to building the pipeline given their existing excellent treatment facilties. In fact the application and pipeline represent a substantial investment. This application is in contravention of Policies N3, N11, and N12 and should be rejected.
   
   The laying of the pipeline and it's route will damage the existing landscape quality and will have a significant adverse impact. No social or economic benefits to this pipeline have been shown at all, and certainly not any of national or local importance. This contravenes Policy N11 and the planning application should be rejected.
   
   The planned pipeline route is outwith the boudaries of Drysdales own land, and crosses the land belonging to the Childrens Trust Dunglass Estate and the intertidal area of the Crown Estates. The pipeline does not require a coastal location (unless you considering "dumping at sea" requires a coastal location!) and the lack of any benefits to building this pipeline given the existing treatment process and licences, does not outweigh the permanent damage to the landscape. The plan contravenes Policy N12 and should be rejected.
2. The proposed pipeline is being laid at an angle across a 1-in-4 cliff that is designated on all geological survey drift maps as unstable. This is the worst way to dig a trench in unstable ground.
   
   We agree with the submissions by TA Dykes and Alistair Skinner who both provide substantial evidence and opinion of the dangers of subsequent landslip and the impact of the permanent changes to the character of this landscape required to bury a pipeline on this slope.
   
   A full, independent, geographical survey must be carried out irrespective of the insensitive location of their pipeline.
3. No assessment has been provided for the potential exposure or rupture of the pipeline in this unstable landscape and the environmental impact of that possibility. This is in contravention of Policy N6 (Environmental Impact). TA Dykes has provided substantial evidence on the effects of trenching in a similar landscape just a short distance east of the proposed pipeline location and concludes that future landslips are not only likely but inevitable. This application must be rejected until a full geological and environmental impact assessment has been carried out.
4. Cutting a trench through this scientifically critical area, that will be there forever, has been described by many as cultural vandalism. Earth scientists from all over the world object to this location being damaged in this way.
5. The suggestion by SNH that the area of concrete trench across the sandstone wave-cut bench will be obscured or softened over time by rock movement or by marine flora and fauna is not supported by the evidence. The platform remains as it has for thousands of years. While there are marine flora (seeweeds) on the platform they have not disguised the varie-coloured sedimentary strata banding in all that time. The impact of a concrete trench at almost right-angles to this banding will not be hidden and will not be softened over time. It will look exactly like a concrete trench hundreds of years into the future. SNHs statement about this is nothing more than idle speculation spouted to defend their position, and is completely contrary to the evidence that is apparent to anyone visiting this area.
6. The revised drawings submitted on 6 September show the pipeline now being laid at almost 2.5m below MLWS. In the objection by Alistair Skinner (a retired Senior Civil Engineer and specialist in waste water treatment and disposal) has called the plans "farcical" and we agree with him when he says the pipeline is likely to be ripped out of it's clamps in the first storm. I was a technical salesman for HILTI where I often carried out destructive testing of anchors (both resin and mechanical) in natural rock and concrete, and was involved in recommending underwater fixing solutions on several occasions. There is no detailed technical specification within the drawings, but they do look inadequate given the exposed location.
7. The proposed pipeline route lies approximately 150m east of the SSSI of Siccar Point. Although SNH say there is no "significant geological interest or value in that location", it is clear from the hundreds of objections from geologists and academics around that world that this is not the view held by these experts. We agree with all the objections to permanently damaging this area.
   
   Scottish Borders Council should not allow a trench to be dug across this important landscape and then allow it to be backfilled with concrete. This will be a highly-visible, permanent, and irreparable change to this significant site, and the application should be rejected on the grounds that it contravences Policy N11 (Areas of Great Landscape Value) and Policy N12 (Coastline) of the SBC Structural Plan. It also contravenes Policy N6 (Environmental Impact) as no Environmental Impact Assessment has been carried out.
   
   However breaking these policies is nothing compared to the damage to this environment and what must be one of the most controversial, destructive, and insensitve planning applications Scottish Borders Council have ever received. If SBC approve this application it would forever mar their reputation and that of SNH, and show Scotland to the world as being culturally, scientifically, and environmentally retarded, putting the interests of a business before protecting this world-famous, critical, geological jewel of a landscape..
8. The damage to the sandstone wave-cut bench will not be restricted to the width of the trench either. Mechanical diggers and tracks will damage the platform to an area several times the width of the trench leaving permanent and irreversable scars on this pristine landscape.

In Summary - The Pipeline Route

In summary, the pipeline is permanently destroying and scarring the landscape in an Area of Great Landscape value for no economic or social gain, and should be rejected on that basis.

The propose pipeline route contravenes Policy N3 (National Sites), Policy N11 (Areas of Great Landscape Value) and Policy N12 (Coastline) of the SBC Structural Plan. It also contravenes Policy N6 (Environmental Impact) as no Environmental Impact Assessment has been carried out.

In additional the applicaton also contravenes Sections 1.17 on sustainable development, Section 1.20 taking into account the views of the community, Section 1.34 Environmental Quality, Section 2.7 conservation of designated sites, Section 2.19 protecting areas covered by landscape designations and to conserve the character of the wider landscape, Section 2.22 in protecting the unobstructed character of the coastal landscape type and their high sensitivity to built development, and Section 6.3 (Waste Management) where the precautionary principle is to "ensure that action is taken now to reduce the potential for damage to the environment or human health in the future" and where "focus should be placed on waste reduction, reuse and recycling, with landfill [and we assume dumping at sea] seen as a last resort for the residual waste".

The planning application should be rejected.

The Effluent

Given Drysdales current system that is licenced by SEPA, there is no economic benefit to building this pipeline. This is highly suggestive that the character or composition of the effluent is likely to change, otherwise there would be no need (and no sense) to build this pipeline.

1. Drysdales have not exhibited any economic or social benefits to building this pipeline as would be required by Policy N11 and N12 of The Scottish Borders Structural Plan entitled "The New Way Forward Scottish Borders Structure Plan 2001 - 2018". As such the application should be rejected.
2. All current recommendations by SEPA are predicated on the existing waste-water treatment process, but the council cannot ignore what changes will occur in the future as a result of this pipeline being built. If no changes were being considered then there is no benefit - and a substantial downside - to building it. Future changes would flow from this application and as such must become a material consideration, not brushed aside. Until the council has all the facts the application must be rejected.
3. If the council is unable to consider future effluent changes as outwith their remit or authority, then they must reject the application given that there are already excellent, and environmentally friendly, treatment methods in place and the pipeline is an unecessary, destructive, and unwelcome development bringing no economic or social benefits in defiance of Policy N11 and N12 of the above mentioned Structural Plan.
   
   It would also contravene Sections 1.17 on sustainable development, Section 1.20 taking into account the views of the community, Section 1.34 Environmental Quality, Section 2.7 conservation of designated sites, Section 2.19 protecting areas covered by landscape designations and to conserve the character of the wider landscape, Section 2.22 in protecting the unobstructed character of the coastal landscape type and their high sensitivity to built development, and Section 6.3 (Waste Management) where the precautionary principle is to "ensure that action is taken now to reduce the potential for damage to the environment or human health in the future" and where "focus should be placed on waste reduction, reuse and recycling, with landfill [and we assume dumping at sea] seen as a last resort for the residual waste".
   
   On this basis, the application should be rejected.
4. SEPA requires the discharge to acheive 50x diltion 95% of the time. Experts who have objected to this plan say this is unlikely to be acheived. The objector Alistair Skinner says ""[this] will not happen, as the discharge point is not far offshore and no dispersion investigations have been carried out. There is therefore a potential risk of back eddies and onshore winds creating a localised anoxic area in the area immediately around the outfall to the detriment of any marine life". Considering SEPA has not carried out any modelling or dispersion tests in the immediate area of the proposed outflow, the application must be rejected until this modelling and testing has been completed.
5. Given the inadequacy of the re-routed pipeline drawings submitted on 6 September, and the point made in point 6 above, it is likely that the pipe will be detached during the first storm in the area. This will result in the outflow only being 500mm from the MLWS seriously affecting the dilution and dispersion of this effluent. The application must be rejected unless more adequate drawings are submitted showing more substantial fixing methods, and Drysdales have provided a method statement regarding how they will re-fix the pipe should it become detached with time-limits on carrying out the repairs.
6. Assuming the newly proposed pipe outflow does remain in place, the location of the outflow directly on the sea bed mean that dilution and dispersal requirements can be achieved. Modelling and testing is required before this application can be considered. As such, the application should be rejected.
7. Although the current outflow of water from the plant does eventually reach the sea it does so via a natural fresh-water outflow (Redheugh Burn). By flowing into the burn the waste water is further diluted by the burn, and nutrients, fertilizer residues, and other organice compounds are absorbed and filtered by plants, soils, and other strata. The marine environment at this natural outflow are acclimatized to this fresh water influx.
   
   Redirecting the waste water to a pipeline means that these natural dilution and absorption processes will not take place. The water will be directed to a different marine location that is not acclimatized to this massive influx of fresh water (up to 360,000 litres per day) and other components such a nutrients, fertiliser and pesticide residues, and potentially chipped vegetable matter depending upon changes to existing waste water treatments.
   
   Marine environments are much more sensitive to change and this will cause a massive changes in the salinity, ph, and nutrient balance, in the new location of the outflow.
   
   Such changes are contrary to the UK Marine Policy Section 2.2 that states: "Biodiversity is protected, conserved and where appropriate recovered and loss has been halted".
   
   Section 2.7 of this policy, which Member States must use as the basis for their more detailed characterisation of good environmental status, states that they must ensure:
   1. Biological diversity is maintained;
   2. The quality and occurrence of habitats and the distribution and abundance of species are in line with prevailing physiographic, geographic and climatic conditions:
   3. All elements of the marine food web, to the extent that they are known, occur at normal abundance and diversity levels capable of ensuring the long-term abundance of the species and the retention of their full reproductive capacity;
   4. Human-induced eutrophication is minimised, especially the adverse effects thereof, such as losses in biodiversity, ecosystem degradation, harmful algae blooms and oxygen deficiency in bottom waters;
   5. Permanent alteration of hydrographical conditions does not adversely affect marine ecosystems;
   6. Concentrations of contaminants are at levels not giving rise to pollution effects;
   7. Properties and quantities of marine litter do not cause harm to the coastal and marine environment;
   
   Without extensive investigation the impact is not known and cannot be known. For SEPA and SNH to say there will be no cause for concern - without evidence that this will be so - is misleading to say the least. In every point immediately above this application is contrary to Section 2.2 and Section 2.7 of the UK Marine Policy Statement and must be rejected on that basis.
8. The objection by Dr Tom Barker of the School of Environmental Sciences at the University of Liverpool, and acknowledged expert in "Ecology, sustainability, ecosystem services" states "Pollution of the marine site. This is likely to lead to localised eutrophication and certainly to disruption of the local ecology, and probably the eradication of the ecosystem at the pipe's end. Downstream there can be expected an increase in production, which could be beneficial to some species, but the overall net benefit is highly dubious and can only be estimated with any confidence after detailed research.", and we agree with him.
   
   The objection by Alistair Skinner says "" There is therefore a potential risk of back eddies and onshore winds creating a localised anoxic area in the area immediately around the outfall to the detriment of any marine life".
   
   Both of these objectors are experts in this area and raise serious concerns regarding the biodiversity and ecology of the marine environment around the outflow. Until further studies and environmental impact assessments are completed this application must be rejected.
9. SNHs own reports on tidal movement in the area between St Abbs and Barns Ness ("Research, Survey and Monitoring Report #143, Coastal Cells in Scotland: Cell 1 - St Abb's Head to Fife Ness (2000) by DL Ramsay and AH Brampton")
10. Local climactic conditions around Siccar Point, where there's often a prevalent north to northeasterly wind, will cause the effluent to be washed up around Siccar Point, and onto the Unconformity itself. Local tidal patterns show (Source: Report p79) that during the ebb tide, effluent will be carried toward Siccar Point, and areas to the north west including Pease Bay, Cove, Thorntonloch, Skateraw, and Barns Ness.
11. Tidal movements between Barns Ness and St Abbs, according to SNH (Source: Report p25 & p79), will not result in the effuent being carried out to sea. The effuent will simply be "smeared" along the coastline between Barns Ness and St Abbs. The more effluent that is pumped into this pristine marine environment, the thicker and more polluting the effluent will become.
12. SNH's own report suggests that there is little movement of beach sediments between the coves and inlets in the area between St Abbs and Barns Ness (Source: Report p26). This means that any effluent that is washed ashore is not likely to be removed by tidal processes.
13. The company process over 14,000 tonnes (source: Drysdales web site) every year. Vegetable processing generates 10%-60% of the raw material as solid waste (Source: Report).
    
    That means Drysdales could produce up to 1400 tonnes* per year at 10% wastage (3.8 tonnes per day on average) and up to 8400* tonnes at 60% wastage (23 tonnes per day on average) of raw vegetable waste. That's not taking into account seasonal variations in output or even the amount of silt and water. Even the smallest figure - 3.8 tonnes of vegetable matter per day - is a huge amount. Current treatements reduce this figure by a significant amount, but if any processes are removed the existing clear water that is produced at the moment will change.
    
    The World Bank (Source: Report) recommend that waste water from raw vegtable production should be treated to remove all solid organic material.
    
    This Report states "The vegetable processing industry generates significant quantities of wastes in some regions. These wastes usually contain high levels of organic matter, nutrients, moisture, and sometimes salts, and are not suitable for disposal in municipal landfills because of their physical, chemical and biological properties. " yet SEPA thinks it's OK to dump this at sea near protected marine habitats.
14. The St Abbs & Eyemouth Marine Reserve is only a few miles down the coast. This area is a mecca for diving enthusiasts and known for its crystal clear waters and huge biodiversity. The local tidal patterns (Source: Report p79) show the effluent will be carried toward this location on the flow tide, not carried out to sea. There's a genuine danger that the crystal-clear waters at St Abbs will be affected by this effluent. Modelling and dispersal testing must be carried out to establish whether this will happen or not.
    
    Given that the economy of St Abbs is largely derived from, and dependent upon, its marine conservation status and its ability to attract divers from all over the world, this is a serious economic threat to the village - and a massive danger to the biodiversity of the marine reserve.
15. The Berwickshire & North Northumberland European Marine Site (which encompasses the St Abbs and Eyemouth Marine Reserve), and has its western edge at Fast Castle, is less than 3 miles east of Siccar point. This is a protected marine environment and will be one of the first "recipients" of the effuent discharge.
16. The volume of effluent will affect the salinity, the ph balance, and the nutrient balance in the immediate local area and will have an effect for miles around. The volume of effluent is not insignificant. It will be TONNES of vegetable matter and THOUSANDS of gallons of water every day the plant is operating. No environment can withstand this onslaught without being seriously affected.
    
    A full environmental impact assessment must be carried out, not just for the immediate area of the pipeline outflow, but for any area that could potentially be affected due to natural water-flow and tidal infuences.
17. A company should not be allowed to replace existing environmentally friendly methods of treating waste water (their reed-beds) by dumping their waste at sea purely for commercial reasons in this modern age.

* - these figures assume the 14,000 tonnes is the raw amount of vegetables processed. If it's the finished processed tonnage that is shipped to their customers then the respective figures would be 1500 tonnes per year (4 tonnes per day on average) at 10% wastage and 21,000 tonnes (57 tonnes per day on average) at 60% wastage. .

Tell Everyone you Can

The more people we can get writing official or unofficial objections, the greater the chance of stopping this. If no-one does anything about it there's a good chance this planning application will be given the green light. Don't let it happen.

Raise an official objection to the plan with Scottish Borders Council

This is the most important thing you can do as this is the official process. The planning application must be approved, and if no-one raises objections the planning application could be passed. You must object to this terrible plan. Here's what to do:

Wednesday 5 September 2012
We've been asked by Scottish Borders Council if we could request that anyone who lives in the UK, and wants to contact them to raise an objection, to use the registration process as described directly below. We appreciate that it is a slightly longer process, but it helps the planning department enormously in making sure your objection quickly becomes part of the official record.

If you live outside the UK, the only contact method available at the moment is via email. For those who have expressed concerns about whether your email will be accepted as part of the record, we know that the planning department are working extremely hard to make sure all emails are added to their site as quickly as possible.

The council may update their system to accept registrations from outside the UK, but it is unlikely this change will take place before the closing date for applications.

Object to the Planning Application by Email

You can also send your objection by email. This may be the best method if you do not live in the UK. Here's how:

We'd be grateful if you didn't send your email directly to Scott Shearer, the person in charge of this application at SBC. Please just use the "prs" and "ped" email addresses below. Your email will reach him.

1. In the Subject Line put "12/00929/FUL Objection Comment"
2. Add your comment in the email body
3. Send your email to prs@scotborders.gov.uk and ped@scotborders.gov.uk

If you want to CC anyone else into your email, you might want to consider:

1. Scottish Natural Heritage: anne.brown@snh.gov.uk.
2. Scottish Environmental Protection Agency: Stephanie.Balman@sepa.org.uk.
3. Crown Estates: enquiries@thecrownestate.co.uk

Crown Estates own the land between the low and high water mark.

Land Owner

We have been informed by Dunglass Estate that the land over which the pipeline will be laid is now held in Trust (Childrens Trust Dunglass Estate) and is managed by the "Trustees of Childrens Trust Dunglass Estate". Dunglass Estate have no direct ownership of this land any more.

The contact details for this trust are:

Ewan Harris
Sale and Partners
Email: ewan@saleandpartners.co.uk

Dunglass Estate

The land where the pipeline will be laid has been kindly placed into trust by Dunglass Estate. Dunglass Estate no longer have any direct involvement in the management or ownership of this land. We extend our sincerest apologies to Dunglass Estate for the huge influx of emails they have received regarding this planning matter. Of course, we'd still be grateful if the Estate would object to the proposed plan, but that is a completely different matter.

Please do not contact Dunglass Estate regarding this issue. They have no direct influence on this planning matter.

Scottish Natural Heritage and SEPA

There are 2 major official agencies who could object to the proposal. They are Scottish Natural Heritage (SNH) and the Scottish Environmental Protection Agency (SEPA).

SNH would have concerns with the protection of the natural heritage of the site, and SEPA would have concerns regarding the untreated effluent waste being poured directly into the sea. Neither agency seems to have raised any strong concerns but they are sensitive to public opinion. It may be worth contacting them to express your view - politely - and ask them to strongly object to this planning application.

Scottish Natural Heritage claim the proposed site is outwith the area of SSSI. That may be strictly true, but the boundaries of the site are not large or extensive and the scarring will be visible and obvious for anyone visiting Siccar point : if the application is allowed the scar will remain as a constant reminder of the practice of official dogma over good sense and an appreciation of the importance of the location.

Note: The contact details and email addresses are publicly available on the documents submitted by these organisations via the Scottish Borders Council web site. If you do contact these people we ask that you are polite and respectful at all times.

The address of SEPA at Clearwater House may have to be renamed if they allow untreated silty water and organic agricultural waste to be pumped untreated into the Firth of Forth....just a few miles up-stream of the popular beaches of Coldingham Sands and Eyemouth and the internationally important marine area at St Abb's Head - we're sure the divers will delight in swimming in a vegetable soup.

Crown Estates

The landowner who could object to the planning applicaton, and possibly stop it in its tracks as the pipeline passes through (under) land that they own. This is Crown Estates.

The Scottish Geodiversity Forum

They were the first to respond to our call for help. They quickly mobilised their members and made a massive difference in not only submitting their objections, but in helping to spread the word so quickly.

They've also helped us keep on top of the factual information on the site. If there are any factual mistakes on the website regarding the geology then they are entirely our own.

Here's the link to the news article on their site.

Jim Kelley at Kelley Marine

Jim has also helped us with geological information and has been great at spreading the work. He was kind enough to share his correspondance with Scottish Natural Heritage and give us permission to reproduce it on the site.

Anonymous

You all know who you are!!

Quite a few people have been kind enough to help us, provide advice, and even given us permission to recreate parts of their correspondence on the web site, but prefer to remain anonymous for various reasons. All of them have made their public feelings known via objections to the plan.

Paul S Braterman

Has written an open letter to the Scottish Borders Council expressing his concerns about the pipeline, it's route, and its effects on the landscape around Siccar Point. Given his impressive credentials Scottish Borders Council should be listening to him.

Here's a link to his open letter.

Garry Hayes

Garry is helping to raise awareness "over the pond" as he puts it and helping our Facebook page and web site attract more visitors.

Unfortuntely for Garry his plans to visit Siccar Point were scuppered by the Foot & Mouth outbreak. Hopefully when he gets a chance to come back the site will still be in its pristine condition.

Here's a link to Garry's Blog.

Dave Thomas

Dave Thomas is a scientist and software engineer working for the IRIS (Incorporated Research Institutions for Seismology) PASSCAL ( (Program for Array Seismic Studies of the Continental Lithosphere) AOF (Instrument Center and EarthScope USArray Array Operations Facility) Programme in New Mexico who carry out cutting-edge seismological research into the Earth's geological structure and processes.

His post and comments at "The Panda's Thumb" is helping to spread the word about this development.

Here's a link to David's Post.

Gunnar Ries

Gunnar has posted a blog on SciLogs, a popular blog for scientists throughout the world for sharing ideas and news. The first picture on his blog is looking back at Siccar Point from a location a little further away than the proposed pipeline, and when the tide is in - the picture makes it obvious just how close this pipeline is to the unconformity.

As he says, people in Germany are "much concerned about the threat to this important site", and hopefully his blog will help to spread the word over there and help to stop this development.

Here's a link to Gunnar's Post.

Scientific American Blog

A blog entry at Scientific American from the geologist David Bressan.

The Geological Society

A Policy and Position Statement from the Geological Society.

Unfortunately, their statement contains a number of inaccuracies that they haven't seem fit to correct despite us pointing them out. For instance:

1. The new pipeline depth is 2.4m to the middle of the outflow, not 3.5m as they state.
2. There is a potential for the effluent to be washed ashore. It's more than that, the effluent WILL be washed ashore, but what effects that has depends upon the effuent character, and we provide evidence that this is probably going to change
3. Saying that the effluent will only contain 100KG of sugars in entirely misleading. That is the COD that their current processing deals with
4. The new pipeline location still doesn't meet SEPA's exact requirements, but 2.4m is close enough not to quibble. It isn't 3.5m as they state as serious doubt have been raised about whether this can acheive SEPA's dilution rates and whether it will provide adequate disperal. Modelling is required.

The Twenty First Floor

A post at the Twenty First Floor (sorry, we don't know the name of the person who posted it).

About.com - Geology

An article by Andrew Alden in the geology section of About.com.

The Fossil Forum

A post by "mzkleen" on the Fossil Forum a very busy and popular internet Forum.

NeuroDojo's Blog

A post by Zen Faulkes an award-winning blogger and invertebrate neuroethologist.

Rob Schneider's Blog

A post by Rob Schneider on his personal blog.

Muck Rack

A post on Muck Rack a popular site frequented by journalists and the media.